The Alberta Energy Resources Conservation Board (ERCB) has released a draft update of Directive 071: Emergency Preparedness and Response Requirements for the Petroleum Industry. Directive 071 is a regulation that requires energy companies operating in Alberta to have an appropriate level of emergency preparedness measures in place. In the broadest context, proposed changes will expand the scope of the regulation, enhance the emergency management process and public safety awareness programs, and suggest changes to ERCB processes.
Corpen Group is ahead of the curve with respect to these upcoming changes and, in addition to having already prepared many larger organizations for regulatory compliance, is now also working to partner with small to mid-sized organizations who will also fall under the same regulatory parameters.
- Changes to ERCB Directive 71 places emphasis on communications
The most significant enhancement to Directive 071, relative to communications, is that companies, during regular audits, must be prepared to submit a crisis communications plan to the ERCB that includes, but is not limited to:
- the communications plan purpose,
- the schedule review,
- the scope and concept of operations,
- objectives,
- activation,
- call-out procedures,
- roles and responsibilities,
- potential audiences,
- immediate action checklists, and
- templates.
In addition to these requirements, your communication plan is also expected to outline specifically how the organization will communicate with affected, impacted and even interested members of the public, key stakeholders, and the media. It must also outline incident-specific risks and considerations and must be tailored to these specific circumstances, targeting appropriate audiences and ensuring that the plan can be implemented in a “timely fashion.” We work with clients to specifically design plans that allow for proof of compliance through both the planning process and in the event of an actual response.
Notably, at the onset of a crisis, the ERCB will require the company to outline their communications approach (for approval) and also provide regularly scheduled updates to all stakeholders that includes, but is not limited to:
- the type and status of the emergency,
- location of the emergency,
- areas affected by the emergency,
- description of the products involved,
- contacts for additional information, and
- actions being taken to respond to the situation, including the anticipated time required.
The ERBC will also require that the plan be exercised and updated on an annual basis. ERCB is proposing that organizations conduct exercises each year, and one of the response capabilities tested will be the organization’s ability to communicate with all stakeholders and follow the defined communications protocols, as well as to address any issues that might develop when the communications plan is implemented.
An essential tool included in every Corpen Group’s crisis communications plan is the expectation that each team member will document all of their communications activities in time and event logs, both for the purpose of evaluating the response post-incident and also in case of incident related legal proceedings. Interestingly, the ERCB will now request a post-emergency report within 30 days of the emergency that includes:
- the nature of the emergency,
- participant names and response positions,
- the sequence of emergency response events, including the activation of the emergency response plan,
- internal and external notification, public protection and downgrading steps,
- an analysis of the extent of the emergency’s impact,
- lessons learned, and
- the action plan and target dates for incorporating the lessons learned into the emergency management program.
The proposed changes to Directive 071 have been presented to industry, and stakeholders are invited to provide feedback on the new requirements before the deadline of January 15, 2013. For a lot of organizations, the expectations outlined in the Directive 071 update have become common practice in crisis communications and emergency response systems, and for others, it may require a sizeable shift in their emergency response policies and procedures.
Small to mid-sized oil and gas companies will face the largest challenges in ensuring compliance, as planning budgets may not be as robust and internal resources may not be adequate or prepared to fulfill the response expectations. At Corpen Group, we are working on a turn-key solution for small to mid-sized oil and gas companies that, when these changes are made official, will ensure quick compliance, from a communications perspective, in the event of an emergency. Larger organizations will also face challenges in adapting their existing, often well-entrenched processes to the requirements of newest draft of the regulation.
Over the last several weeks we have been working with industry associations and organizations within the energy industry to ensure an easy transition into compliance. Over the years we have had extensive experience working with the previous version of Directive 071 and petroleum companies that operate within Alberta; developing plans and strategies that are focused on communicating with integrity, accountability and transparency, to meet, and often exceed, societal expectations of companies during emergency situations.
If you would like more information about Corpen Group’s Directive 71 compliance program, or any aspect of crisis or critical communications, please contact Greg Vanier at gregvanier@corpengroup.com or 403-476-6922.
